In what circumstances will the US Supreme Court uphold a jury's refusal to return a verdict of manslaughter?

California, United States of America


The following excerpt is from People v. Williams, 106 Cal.Rptr.2d 295, 21 P.3d 1209, 25 Cal.4th 441 (Cal. 2001):

In that case the United States Supreme Court found no error in the trial court's instructions, or in its refusal to instruct the jury that it could return a verdict of manslaughter. The high court conducted an exhaustive review of the authority then available, which repeatedly and consistently supported a single view, aptly stated as follows: "`"It is true, the jury may disregard the instructions of the court, and in some cases there may be no remedy. But it is still the right of the court to instruct the jury on the law, and the duty of the jury to obey the instructions."'" (Sparf v. United States, supra, 156 U.S. 51, 72, 15 S.Ct. 273, 39 L.Ed. 343.) The high court concluded: "We must hold firmly to the doctrine that in the courts of the United States it is the duty of juries in criminal cases to take the law from the court, and apply that law to the facts as they find them to be from the evidence. Upon the court rests the responsibility of declaring the law; upon the jury, the responsibility of applying the law so declared to the facts as they, upon their conscience, believe them to be." (Id. at p. 102, 15 S.Ct. 273.)

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